Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.
Why do I need an SDS for a Laptop Battery?
Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.
The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.
Manufacturer’s Packaging (Lithium Battery)
Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…
The Emergency Response Guidebook published by the US Department of Transportation, developed jointly with Transport Canada and the Secretariat of Transport and Communications is used by firefighters, police, and other emergency response personnel who may be the first to arrive on the scene of a transportation incident regarding dangerous goods/hazardous materials.
The primary purpose of the Guide is to provide immediate information regarding the chemical, therefore allowing them to take appropriate action to protect themselves and the general public.
Changes and Updates You Should Know About:
The 2016 edition includes changes such as:
Expanded/Revised sections on:
How to use this guidebook (flowchart)
Table of placards and markings
Rail car/road trailer identification charts
ER telephone numbers
New Sections include:
Table of contents
Information on GHS (Globally Harmonized System of Classification and labeling of Chemicals)
Information about ERAP (Emergency Response Assistance Plans)
In our dangerous goods world we all know the importance of labelling, packaging, and disposing of lithium batteries. As many of you know we offer training, consultation, packaging, and re-packaging for shipping lithium batteries, and for good reason. While lithium batteries are becoming more and more prevalent in our society, so are the risks involved, like the video below:
According to the FAA as of January 24, 2018, there were 191 air/airport incidents involving lithium batteries carried as cargo or baggage that have been recorded since March 20, 1991.
And just to clarify, these are just the recent cargo and baggage incidents that the FAA is aware of. Most of these incidents included smoke, fire, extreme heat or explosion involving lithium batteries or unknown battery types. Incidents have included devices such as E-cigarettes, laptops, cell phones, and tablets. The severity of these incidents ranged from minor injuries to emergency landings.
Visit FAA’s website for the complete list of incidents:
A freight forwarder contacted me to get some help on shipping perfume to Hong Kong. I asked him how he is sending it and he replied, “Air.” I said, “That’s simple.” It would fall under ID8000, Consumer Commodity. Explained to him what that actually meant. Basically, it’s goods that are “packaged and distributed in a form intended or suitable for retail sales for purposes of personal care or household care”; however, there are a few restrictions such as only certain hazard classes and packing groups are permitted. Perfume definitely falls within the criteria.
He came by our office and dropped off 8 decent sized boxes of these goods. I asked the forwarder if he plans on shipping the boxes individually or will be consolidating them (e.g, on a pallet). He said his plan was to take the boxes back to the office once I prepare the boxes and he will palletize it. I advised him he can’t do that, because that would be considered an “overpack” and would require marking and labeling on the outside of the shrink wrap (assumed it would be shrink wrapped). He said “Oh”. I told him we could help him. We will provide the shrink wrap and prepare the shipment completely at our location. He said he already had a heat-treated pallet (all wooden pallets must be heat-treated Continue Reading…
Well, nothing, if you consider where it was taken (a remote town in Thailand).
Even while on vacation, someone in the Dangerous Goods field is always on the lookout for dangerous goods in their environment. I know when I first joined ICC, I never noticed placards on trucks, but soon after it seemed like they were on every transport that passed by. Those blessed to be in our line of work have a heightened awareness for the dangers around us.
As we all know, regulations concerning dangerous goods differ around the globe. As much as we would like to think the regulations are harmonized, they’re really not. Enforcement is the same. There are only so many inspectors available compared to the number of shipments each day.
One has to wonder what training these workers have. Where are the transport labels, the Hazcom labels, and the blocking and bracing?
I feel a lot more comfortable knowing that shipments of gases in the US and Canada will be properly secured when transported, and they will always have proper labels. Regulations are in place for one reason, and that is to protect workers and the community.
ICC is your source for products, services, and training – all under one roof. Call us today.
Shipping Dangerous Goods During the Holiday Season
If you ask for any of these things for Christmas, Santa may not be happy. All of the items below are in one-way or another, regulated as Dangerous Goods under the IATA regulations, thus, they cannot simply be placed in Santa’s sleigh. I wonder if Santa has a Dangerous Goods Coordinator or is current on his training.
Most perfumes are flammable. Santa may be able to use the Limited Quantity exemption, but it will still need a label and a completed Shipper’s Declaration form.
9. Oil-based paints
Hoping to get some paint from Santa this year? Paints are also flammable, and depending on the flashpoint and volume per package, may have to be shipped fully regulated.
Asking for a hoverboard will certainly put you on the naughty list. Most hoverboards are manufactured in China, and many do not have Lithium Battery Test data (UN 38.3). Furthermore, depending on the Watt Hour rating, these may not even be able to be shipped in his sleigh!
7. Vanilla Extract
Hoping for some Vanilla to replenish your stock after making all those cookies for Santa? Vanilla, in its concentrated form is flammable. Let’s hope the bottle is small enough to get an exemption such as those under excepted, de minimis or limited quantity.
My family has always been made up of people who like to read. It starts with the little ones being read to by others and generally leads to a love of independent reading later in life. I saw the process start with the next generation during the recent United States’ holiday of Thanksgiving. In order to get the 18-month old to settle down for a nap his father read to him. Funny enough, the story was that of Chicken Little. For those that don’t remember the story it is about Chicken Little getting hit on the head by an acorn and thinks the sky is falling. To protect friends and family the character decides to go tell the king. On the way, Chicken Little meets various friends and proceeds to tell each of them that the sky is falling. Hearing the refrain of “the sky is falling” said throughout the telling of the story it got me thinking …
The Sky is… Not Falling?
What if rather than panicking about the event Chicken Little followed proper procedure? When handling hazardous materials there must be plans in place to handle accidents. This includes spills and injuries at your location and more importantly during transport. One such procedure is set in 49 CFR for US ground transportation. In Section 172.604 it states that an emergency response telephone number must be Continue Reading…
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.
Lithium Battery Special Provision
Q. Why is only a reference to Packing Instruction Section IB required on a lithium battery Shipper’s Declaration – what about shipments made under Section I or IA?
A. Sections I and IA refer to fully regulated shipments so it’s redundant to indicate an authorization unless there’s a special provision deviation involved.
Although Section II shipments don’t require a Shipper’s Declaration document, if an airwaybill is used a notation must be made indicating the Section II status like “Lithium ion batteries in compliance with Section II of PI— CAO”.
This is particularly true for UN3090 or UN3480 where the document is required to indicate the CAO status.
Shippers also need to verify any listed state or operator variations that may require information over that mandate by IATA DGR.
Determining the Size of the Package
Q. I have a customer who wants a “portable tank” of product instead of our usual smaller sized containers, can I oblige?
Characterize your product,
read the container supplier’s specification,
read the relevant regulation,
read the cited container standard; review 1. & 2. in the context of 3. & 4; decide on any required modifications.
As you may have heard, a major hazmat incident occurred in Niagara Falls, not far from ICC Compliance Center’s location. On a late Monday night in October, a tanker truck carrying nearly 13,000 gallons of liquid hydrogen (UN1966) hit the base of a light pole in the parking lot of a local grocery store as the driver was attempting to turn around. This resulted in a valve on the truck to become damaged and could have caused the highly flammable liquid hydrogen to be released from the truck triggering a very serious situation for nearby residents and businesses. Although the driver received a traffic violation, nobody was physically harmed by the incident. Watching this news story unfold made me think about how this incident could have turned out much differently if hazmat protocol wasn’t followed.
As the tanker truck crashed into the pole, local officials on hand realized the dangers of what was inside the truck because it was properly placarded with a UN1966 placard. Had the truck not been placarded correctly, officials would not have known what was inside the truck and what dangers could come from exposure to the highly flammable liquid hydrogen. As a result, officials were able to respond quickly and evacuated all local businesses and roads leading to the grocery store parking lot the accident took place in. Officials Continue Reading…
The idea of zombies, the undead, and those things that come back from the grave have been around in society as far back as 1932. That was the year Bella Lugosi starred in the movie “White Zombie”. This was followed by other classic horror movies such as “Night of the Living Dead”, “The Serpent and the Rainbow” and “World War Z”. Zombies have even moved into mainstream TV. We now have “iZombie”, “The Walking Dead” and “Z Nation” to name a few. In each of those, zombies are created by a virus, radiation exposure, mutations or even voodoo curses. What makes for good entertainment are the stories of people evading or escaping from them. After all, the main source of food for a zombie is the human brain.
It begs the question then, could you survive a fictional zombie apocalypse?